How can employees demonstrate knowledge and understanding of the required subjects, as required by the silica standard?

There is no set method employers must use to ensure employees demonstrate knowledge and understanding of the required subjects. Instead, the standard defines employers’ training obligations in terms of performance-oriented objectives meant to ensure that employees are aware of the hazards associated with silica in their workplace and how they can help protect themselves. However, as a general matter, employers can determine whether employees have the requisite knowledge through methods such as discussion of the required training subjects, written tests, or oral quizzes. See 81 Fed. Reg. at 16845.

The requirement for training is performance-oriented in order to allow flexibility for employers to provide training as needed to ensure that each employee can demonstrate the knowledge and understanding required under the rule. Although the standard does not set a fixed schedule for periodic training, additional or repeated training may be necessary under certain circumstances. For example, if an employer observes an employee engaging in activities that contradict knowledge gained through training, it is a sign to the employer that the employee may require a reminder or periodic retraining on work practices. See 81 Fed. Reg. at 16850.